date:20220326

Re: [PSES] RED DoC and ETSI EN 301 489-1

2022-03-26 Thread Charlie Blackham

Gert




Indeed, but it implies that for the RED another compliance route need to be 
choosen (see annexes to the RED)

I’m not sure what you mean by this statement – the manufacturer can follow 
Annex II and self declare where HS have been applied for article 3.2 (and 3.3 
if applicable) irrespective of whether HS have been applied for Article 3.1(a) 
and (b) – this is laid out in Article 17.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Gert Gremmen 
Sent: 26 March 2022 10:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RED DoC and ETSI EN 301 489-1






The trend is to not harmonise the -1 version of this (and other series) in the 
future,

the -1 instead will be normatively referenced in any of the applied subparts, 
that WILL be harmonised (once approved).

By normatively referencing, the referenced clauses from the -1 will be part of 
the "text with legal effect" in the subpart.









This implies that you will need a third party to prove your compliance status 
i.e. a Notified Body for 2014/53/EU (art 3.2)









Indeed, but it implies that for the RED another compliance route need to be 
choosen (see annexes to the RED)



The many subparts of EN 301 489 are on their way to harmonisation.

However the process of creating standards (= adapting to EU requirements) is 
slow, and many stakeholders are involved.

Since to-be-listed standards need up to 4 HAS-assessments each followed by a 
round of modifications at ETSI,

each taking 3-9 months, the delays can be huge.



(HAS is the EU-process where candidate HS are being scrutinized for their 
suitability to be listed. To a great part this comes down

 on verifying if the presented requirements can stand up in a legal sense, are 
exhaustive and precise,

contain no duplicates to EU legislation, and are to the state of the art.

In some cases a normatively referenced standard can block harmonisation if the 
referenced standard has severe deficiencies.)





Gert Gremmen


On 26-3-2022 9:21, T.Sato wrote:

Although non-harmonised standards will not give presumption of conformity,

--

Independent Expert on CE marking

EMC Consultant

Electrical Safety Consultant
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Re: [PSES] RED DoC and ETSI EN 301 489-1

2022-03-26 Thread Gert Gremmen

years. It's also possible that EU legislation has changed during that time.>


Indeed, there is an urgent need to speed up the process of standards 
creation/modification, as both have happened, though it is more a 
process of iteration to get to a final acceptable result.


That said, the consensus process in creating standards is difficult to 
upgrade, seen how this is currently organized.


An quite ambitious effort of the Commission ( 
https://ec.europa.eu/commission/presscorner/detail/en/ip_22_661) to 
limit the decision  process  for EU-standards to EU stakeholders  (only) 
may help.


(This has of course the added inconvenience of creating a potential 
divergence between International and European versions of standards, I 
personally believe however, that the majority of the world will follow 
the EU-versions, simply because it is too expensive to create multiple 
approved versions of equipment. )


but most "field" problems are not caused by state of the art problems, 
but occur due to insufficient knowledge of technical committees on legal 
concepts, by for example allowing 2 different but (thought) equivalent 
tests for one requirement. The uncertainty caused by having the 
manufacturer make an open choice between 2 test methods is legally not 
acceptable. If test are different, than it means that there can be 
different results under different test conditions. Otherwise a single 
test would be sufficient as specification. Creating sufficient guiding 
to support 2 tests can be quite challenging, if this needs to be precise 
and exhaustive. Gert Gremmen


On 26-3-2022 11:50, John Woodgate wrote:
The 'state of the art' is quite likely to have moved on in less than 3 
years. It's also possible that EU legislation has changed during that 
time.


--
Independent Expert on CE marking
EMC Consultant
Electrical Safety Consultant

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adr:;;Lieu Dit Pirot;Chauffailles;;71170;France
email;internet:g.grem...@cetest.nl
tel;cell:+33 7 84507010
note;quoted-printable:Independent Expert on CE marking =
	=0D=0A=
	Harmonised Standards (HAS-) Consultant @ European Commission for RED, LVD=
	 and EMC=0D=0A=
	EMC Consultant=0D=0A=
	Electrical Safety Consultant=0D=0A=
	
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Re: [PSES] RED DoC and ETSI EN 301 489-1

2022-03-26 Thread Gert Gremmen

the standards to which they were tested.>

The trend is to not harmonise the -1 version of this (and other series) in the 
future,
the -1 instead will be normatively referenced in any of the applied subparts, 
that WILL be harmonised (once approved).
By normatively referencing, the referenced clauses from the -1 will be part of the 
"text with legal effect" in the subpart.




This implies that you will need a third party to prove your compliance status 
i.e. a Notified Body for 2014/53/EU (art 3.2)



 
Indeed, but it implies that for the RED another compliance route need to 
be choosen (see annexes to the RED) The many subparts of EN 301 489 are 
on their way to harmonisation. However the process of creating standards 
(= adapting to EU requirements) is slow, and many stakeholders are 
involved. Since to-be-listed standards need up to 4 HAS-assessments each 
followed by a round of modifications at ETSI, each taking 3-9 months, 
the delays can be huge. (HAS is the EU-process where candidate HS are 
being scrutinized for their suitability to be listed. To a great part 
this comes down on verifying if the presented requirements can stand up 
in a legal sense, are exhaustive and precise, contain no duplicates to 
EU legislation, and are to the state of the art. In some cases a 
normatively referenced standard can block harmonisation if the 
referenced standard has severe deficiencies.) Gert Gremmen


On 26-3-2022 9:21, T.Sato wrote:

Although non-harmonised standards will not give presumption of conformity,


--
Independent Expert on CE marking
EMC Consultant
Electrical Safety Consultant

-

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begin:vcard
fn:Gert Gremmen
n:Gremmen;Gert
adr:;;Lieu Dit Pirot;Chauffailles;;71170;France
email;internet:g.grem...@cetest.nl
tel;cell:+33 7 84507010
note;quoted-printable:Independent Expert on CE marking =
	=0D=0A=
	Harmonised Standards (HAS-) Consultant @ European Commission for RED, LVD=
	 and EMC=0D=0A=
	EMC Consultant=0D=0A=
	Electrical Safety Consultant=0D=0A=
	
x-mozilla-html:TRUE
version:2.1
end:vcard

Re: [PSES] RED DoC and ETSI EN 301 489-1

2022-03-26 Thread T.Sato

On Fri, 25 Mar 2022 21:28:48 +,
  Ryan Jazz  wrote:

> We have a Short Range Device transmitter and corresponding receivers we 
> install in various enclosures for which we have test reports from different 
> US labs.
> Transmitter power is less than 10mW and uses the 2.4GHz band.
> The various reports issued show the ETSI EN 301 489-1 V1.9.2 as one of the 
> standards to which they were tested. The other is EN 300 440 V2.1.1.
> 
>   *   My question is how do we show this ETSI standard in the RED Declaration 
> of Conformity when this standard is listed only in the OJEC under the EMC 
> Directive?
> Many RED guidance articles mention the EMC Directive should not be identified 
> in the RED DoC.
> Is it OK to list this ETSI standard under the RED Directive-I am afraid it 
> would be misleading or raise a red flag. (pun unintended).
> Instead of this ETSI standard, should we list the EN 55035:2017 standard 
> instead, which is published in the OJEC under the RED?

Annex VI of the Directive clearly says:

  6. References to the relevant harmonised standards used or
  references to **the other technical specifications** in relation to
  which conformity is declared. ...

Although non-harmonised standards will not give presumption of conformity,
I believe we can list any non-harmonised documents in the DoC.

Regards,
Tom

-- 
Tomonori Sato  
URL: http://t-sato.in.coocan.jp

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Re: [PSES] RED DoC and ETSI EN 301 489-1

2022-03-26 Thread Charlie Blackham

Ryan
EN 301 489-1 V1.9.2 is in the EMC OJ to be used alongside EN 301 489-34 for 
phone chargers. EN 301 489-1 V1.9.2 is quite old and I would argue does not 
represent "state of the art".
EMC Directive Harmonised Standards (HS) are useful when considering EMC aspects 
of non-radio functions for radio equipment (for example EN 61326 series of 
standards for radio enabled measurement and laboratory equipment)
EN 55037:2017 is only relevant under the RED to Broadcast Receivers (as per 
Annex ZZB),  and should not be applied to other equipment out of scope.
There is no requirement to use HS for EMC requirements under the RED (and it is 
impossible to do so, as non of the 301 489 series are yet listed)
Manufacturers must document a Risk Assessment that details rationale for 
standards that have been applied to demonstrate compliance with all relevant 
articles and I recommend that this includes application of the latest versions 
of EN 301 489 standards as published by ETSI which is likely to require some 
additional testing
Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Ryan Jazz 
Sent: 25 March 2022 21:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED DoC and ETSI EN 301 489-1

Dear members,
We have a Short Range Device transmitter and corresponding receivers we install 
in various enclosures for which we have test reports from different US labs.
Transmitter power is less than 10mW and uses the 2.4GHz band.
The various reports issued show the ETSI EN 301 489-1 V1.9.2 as one of the 
standards to which they were tested. The other is EN 300 440 V2.1.1.

  *   My question is how do we show this ETSI standard in the RED Declaration 
of Conformity when this standard is listed only in the OJEC under the EMC 
Directive?
Many RED guidance articles mention the EMC Directive should not be identified 
in the RED DoC.
Is it OK to list this ETSI standard under the RED Directive-I am afraid it 
would be misleading or raise a red flag. (pun unintended).
Instead of this ETSI standard, should we list the EN 55035:2017 standard 
instead, which is published in the OJEC under the RED?
I would appreciate your valuable advice.
Sincerely Yours,
Ryan Jazz
Ryan Jayasinghe
Regulatory Compliance Engineer
rjayasin...@line6.com

"After silence, that which best expresses the inexpressible, is music" - Aldous 
Huxley

LINE6
26580 Agoura Road
Calabasas CA 91302
818.575.3711
line6.com
ampeg.com

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Re: [PSES] RED DoC and ETSI EN 301 489-1

Re: [PSES] RED DoC and ETSI EN 301 489-1

Re: [PSES] RED DoC and ETSI EN 301 489-1

Re: [PSES] RED DoC and ETSI EN 301 489-1

Re: [PSES] RED DoC and ETSI EN 301 489-1

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